EUR 3 Customs Duty and Union Handling Fee: Declaring From 1 November

The European Commission’s Directorate-General for Taxation and Customs Union (DG TAXUD) has issued a version of its EUR 3 customs duty guidance dated 5 October 2026, and the title now names a second charge: the Union handling fee. Since 1 July 2026, Article 2 of Council Regulation (EU) 2026/382 has imposed a temporary EUR 3 customs duty per item in consignments with an intrinsic value not exceeding EUR 150 where the importation qualifies for the IOSS import VAT exemption or the goods fall within the definition of a postal consignment. The handling fee, set at EUR 2 per item by a Commission delegated act dated 21 September 2026 (C(2026)6694, which the guidance marks as under scrutiny), applies to goods sold in distance sales and declared for release for free circulation at any consignment value, and the guidance expects it to apply from 1 November 2026, the tenth day after the delegated act’s entry into force. The Official Journal publication of that act is the legal trigger for the start date.

For the people who lodge H1, H6 and H7 import declarations (IOSS holders, special-arrangement users, postal operators and indirect customs representatives), the change is arithmetic and data. Both charges are computed per declaration line. The guidance says the fee is triggered by TARIC document code Y126 on every distance-sale declaration from 1 November 2026, the same date from which merchant and manufacturer product identifiers are scheduled to become mandatory. Once the fee applies, the guidance applies both charges per declaration line irrespective of quantity, so each extra line in a consignment up to EUR 150 carries the EUR 3 duty plus the EUR 2 fee at the amount set in the delegated act, while a line in a larger consignment carries the EUR 2 fee on top of duty at the normal tariff rate.

The guidance is explanatory and not legally binding. The obligations sit in Regulation 2026/382, the new Union Customs Code (Regulation (EU) 2026/2108), the amended UCC Delegated and Implementing Regulations and the fee-setting delegated act, and national instructions may add to them.

Related reading: EU Customs Reform: The Data Hub Timeline for Importers and Traders

Key dates for the EUR 3 customs duty and the Union handling fee

• 1 July 2026: the EUR 150 customs duty relief in Articles 23 and 24 of Regulation (EC) No 1186/2009 is deleted and the EUR 3 per-item duty applies. The amended UCC Delegated and Implementing Regulations apply from the same date, and product identifiers may be provided voluntarily.
• 20 September 2026: Regulation (EU) 2026/2108, the new Union Customs Code, enters into force. Its definitions of distance sales, consignment and item, and its rule on who lodges distance-sale declarations (Article 85(2)), apply from that day under Article 287(3).
• 21 September 2026: the Commission adopts delegated regulation C(2026) 6694 fixing the handling fee at EUR 2 per item.
• 1 October 2026: deadline for the first Commission assessment of trade diversion under Article 3 of Regulation 2026/382, with an assessment every month thereafter.
• 5 October 2026: version date of the updated DG TAXUD guidance.
• 1 November 2026: product identifiers are scheduled to become mandatory; TARIC code Y126 is to be declared for distance sales; the handling fee is expected to apply.
• 21 September 2027: general date of application of the new Union Customs Code.
• 1 December 2027: Commission assessment of whether the EU Customs Data Hub can levy duties on distance sales by 1 July 2028.
• 30 June 2028: last day of the transitional declarant cascade in Article 85(2) of the new Code.
• 1 July 2028: the EUR 3 duty ends and distance sales of any value pay normal duty; the customs warehouse for distance sales (Article 145 of the new Code) and its lower handling fee apply.

The 1 November date for the fee is an expectation. Article 287(4) of the new Code applies the fee from the tenth day after the delegated act enters into force, and the act enters into force on publication in the Official Journal. The 5 October guidance still describes it as under scrutiny.

What changed between the June and October versions of the guidance

The version dated 2 June 2026, published alongside the Commission’s 8 June 2026 news item, was titled “Importation and exportation of low value consignments: The EUR 3 temporary customs duty” and dealt only with the duty. Its VAT section said the existing IOSS, special arrangements and standard procedures were unchanged and that future updates would cover the VAT treatment. Set against that June text, the 5 October version adds or changes the following:

• New chapters on the Union handling fee: its legal basis in Article 20 of the new Code, its EUR 2 amount, its scope, its debtor, its non-refundability and its declaration through TARIC code Y126.
• A VAT chapter stating that the handling fee forms part of the VAT taxable amount, with separate treatment for IOSS, special arrangements and the standard procedure.
• A firmer position on customs warehouses. June said the Commission was considering amending Article 201 of the UCC Delegated Regulation to reflect the rule that customs warehouse storage facilities are not to be used for retail sale; October says it is in the process of amending Article 201(e) so that goods sold to consumers while stored in a customs warehouse are also subject to import duties, such as the EUR 3 duty, and to the fee.
• H1 listed as mandatory for consignments above EUR 150, and an explicit statement that H7 cannot carry excise goods.
• A planned reduction of the comprehensive guarantee for Authorised Economic Operators, with monitoring expectations for AEO criteria.
• Annex I, which sets out the data elements Member States can use to calculate the EUR 3 duty in national declaration systems.
• A narrower product identifier scope: June said the requirement applies to all goods sold in distance sales from 1 November 2026, while October says the Commission is amending Annex B to limit it to goods with an intrinsic value not exceeding EUR 150.

The warehouse, guarantee and product identifier changes all describe amendments the Commission says are still in progress.

The legal chain behind the duty and the fee

Council Regulation (EU) 2026/382 of 11 February 2026 does two things. Article 1 deletes Chapter V of Title II of the Duty Relief Regulation, which held the EUR 150 negligible-value relief. Article 2 imposes a customs duty of EUR 3 per item, from 1 July 2026 until 1 July 2028, in a consignment whose intrinsic value does not exceed EUR 150, in two cases: where the import is VAT-exempt under Article 143(1)(ca) of the VAT Directive (the IOSS route), or where the goods are in a postal consignment as defined in Article 1(24) of Delegated Regulation (EU) 2015/2446.

Point (b) depends on a definition that Delegated Regulation (EU) 2026/1022 rewrote. “Goods in postal consignment” now means goods in a consignment of an intrinsic value not exceeding EUR 150 sold in distance sales of imported goods, excluding IOSS-exempt imports and goods benefiting from preferential measures. The carrier is irrelevant to the definition. A courier parcel declared under the special arrangements or the standard VAT procedure falls under point (b), which is how the guidance reaches its conclusion that the duty applies regardless of VAT scheme and regardless of whether H1, H6 or H7 is used. Where the old concept of postal carriage still matters (entry summary declarations, the H6 declaration under Article 144 and acts deemed to be declarations), the Delegated Regulation now uses “goods conveyed under the responsibility of a postal operator”.

The fee has a separate chain. Article 20(2) of Regulation (EU) 2026/2108 requires customs authorities to collect a Union handling fee of a fixed amount per item for handling a request to release goods sold in distance sales for free circulation. Article 20(10) empowers the Commission to set the amount by delegated act, and C(2026) 6694 of 21 September 2026 does so in one sentence: EUR 2 per item. The act enters into force on publication in the Official Journal and applies from the tenth day after, aligned with Article 287(4) of the Code.

Implementation detail sits in two amending acts that both apply from 1 July 2026: Delegated Regulation (EU) 2026/1022 (definitions, declarations, data elements and product identifiers) and Implementing Regulation (EU) 2026/1200 (competent office, item grouping, anti-abuse, postal labels and the code changes in Annex B).

Which consignments carry the EUR 3 duty

The guidance tests four elements of a distance sale, built on Article 14(4), point (2), of the VAT Directive. The goods are supplied by a taxable person, including a platform acting as deemed supplier under Article 14a. The customer is in the Union customs territory. The goods are in a third country or territory at the time of supply. And the goods are dispatched by or on behalf of the supplier, which includes subcontracted carriers, transport fees invoiced and passed on by the supplier, and delivery services the supplier promotes or arranges.

For that fourth element, only collection by the customer, or transport the customer arranges without any intervention of the supplier, takes the goods outside. New means of transport and goods supplied after installation or assembly fall outside distance sales altogether.

Three scope points cut against intuition:

• The customs territory includes the special fiscal territories where the VAT Directive does not apply, such as the Aland Islands and Mount Athos. The duty and the fee apply to goods moving into those areas.
• The goods listed in former Article 24 of the Duty Relief Regulation (alcoholic products, perfumes and toilet waters, tobacco products), which the old relief did not cover, are now inside the EUR 3 duty. Whether goods are dispatched directly to the consignee no longer matters either.
• Because both charges are fixed amounts, the guidance states there is no need to establish a customs value or identify the transaction value for these imports. The EUR 150 test runs on intrinsic value as defined in Article 1(48) of the UCC Delegated Regulation, which excludes transport and insurance costs unless they are included in the price and not shown separately on the invoice.

Customs warehouses split into two cases. Goods sold to consumers before they are stored in a customs warehouse, where the warehouse activity is aimed at preparing them for final distribution, count as dispatched from a third country, so the fee applies to them, and so does the EUR 3 duty where the consignment’s intrinsic value does not exceed EUR 150. Goods sold while already stored are the subject of the pending Article 201(e) amendment. The dedicated customs warehouse for distance sales in Article 145 of the new Code applies only from 1 July 2028.

Bulk imports that contain individual sales are covered by Article 243(5) of the UCC Implementing Regulation. Where verification shows a series of successive sales and one of them is a distance sale, customs considers only the distance sale. The guidance lists indicators, among them individual labels or barcodes inside a bulk consignment, the frequency of declarations by the same operator, and a missing buyer in the H1 data. Customs may then recalculate the debt per item before release, require a guarantee, or invite the declarant to invalidate and lodge a new declaration, in which the IOSS cannot be used.

Counting items: the declaration line sets the bill

An item, under Article 5(78) of the new Code and the new Article 1(61) of the UCC Delegated Regulation, is one or more goods in a consignment sharing the same tariff classification, description and, where the dataset requires it, origin. Article 222 of the Implementing Regulation treats each item on a declaration as a separate declaration. The amended Article 228(1) switches off the usual option to group goods under the highest applicable duty rate where the EUR 3 duty applies.

The guidance then adds the operational rule that drives every calculation: because of IT system limits, the EUR 3 duty and the handling fee apply automatically per declaration line, whatever the quantity on that line. Recital 4 of Delegated Regulation 2026/1022 closes the obvious gap: identical goods declared on separate lines pay the duty on each line.

The dataset therefore changes the bill. The guidance’s worked example is a EUR 140 consignment from China, sold under the IOSS, containing three different women’s suits:

Origin matters only where the dataset carries it. In the guidance’s H1 bicycle-parts example, five carbon-fibre parts from China and one part from Thailand share TARIC code 8714 91 10 31 but sit on two lines because origin differs, and two aluminium frames under 8714 91 10 35 take a third line. That makes three lines, each carrying EUR 3 and, once applicable, the fee. The guidance also states that the classification according to Annex B prevails for both charges.

For a declarant, the line count is now a cost driver that needs the same control as classification. A system that splits lines for presentation reasons, or that cannot keep identical goods on one line, pays the duty, and later the fee, once per line.

The EUR 2 Union handling fee: any value, per item, no refund

The fee pays for the customs service of handling a release request. Article 20(3) of the new Code says it covers at least the cost of checking data, risk analysis, the relevant infrastructure and controls, including services of the EU Customs Authority. The explanatory memorandum to the delegated act says the amount was estimated from customs costs and the volume of items valued up to EUR 150, which the Commission calls a conservative approach because higher-value distance sales, also subject to the fee, were left out of the count.

Three features separate it from the EUR 3 duty:

• Value: the fee applies to goods sold in distance sales whatever the consignment value. A EUR 400 distance-sale consignment pays duty at the normal tariff rate plus EUR 2 per item.
• Duration: the fee has no end date. The duty ends on 1 July 2028; the fee continues, and Article 20(4) requires a lower amount for goods released from a customs warehouse for distance sales from that date. The delegated act deliberately leaves that lower amount unset for now.
• Preference: goods claiming preferential tariff treatment escape the EUR 3 duty when declared in H1 outside the IOSS, but the guidance states that preferential goods sold in distance sales remain subject to the fee.

Article 20(5) makes the debtor of the import customs debt also the debtor of the fee, and where there is no customs debt, the person who would have been the debtor. Matters not specifically regulated follow the customs debt rules by analogy. The fee is incurred when the declaration is accepted, in the Member State where it is lodged and the goods are presented.

Article 20(6) makes the fee non-refundable, and the guidance walks through what that means. No acceptance, no fee. Acceptance followed by refused release: fee due. Acceptance followed by invalidation: fee due, because customs handled both requests.

Debt incurred through non-compliance: no fee, because there was no request to handle, and the guidance expects penalties under Article 42 of the UCC to address the non-compliance. A declaration later found to rest on false information: customs notifies the uncollected fee.

On the declaration, the guidance states that from 1 November 2026 declarants must include TARIC document code Y126 in data element 12 04 002 000 (Additional Reference Type) on H1, H6 and H7 declarations for distance sales, and that declaring the code triggers the fee automatically. It also describes a new tax type code, F00, for the fee in Annex B of the Implementing Regulation; the link to that amendment is marked “to be added as soon as adopted”.

H7, H6 or H1: dataset rules and the codes that go with them

The amended Articles 143a and 144 of the UCC Delegated Regulation set who may use which dataset. The person lodging the declaration chooses among the datasets whose conditions are met.

Three Annex B codes identify the VAT route in data element 11 10 000 000 (Additional Procedure): F48 for IOSS, F49 for the special arrangements, and F53 for low-value goods under the standard VAT procedure. Implementing Regulation 2026/1200 deleted C07, the code for consignments of negligible value, because the relief it described no longer exists; F53 takes its place where C07 could not be combined with F48 or F49.

Preference sits in data element 14 11 000 000. Code 5 marks goods subject to the EUR 3 duty under Regulation 2026/382. Codes 2, 3 and 4 (the first digit of the three-digit preference code, for GSP, other tariff preferences and customs union agreements) remain available only in H1 and only where the VAT was not collected through the IOSS, since the Regulation imposes the flat duty on every IOSS import.

The office of lodgement follows the VAT route. With the IOSS, the declaration may be lodged in any Member State, and the customs debt is incurred there. Without it, the amended Article 221(4) of the Implementing Regulation requires a distance-sale consignment with an intrinsic value up to EUR 150 to be lodged in the Member State where transport or dispatch ends, so that import VAT is calculated correctly.

The declarant cascade and who ends up as debtor

Until 30 June 2028, Article 85(2) of the new Code lists who lodges a distance-sale declaration, and the notes to data element 13 05 000 000 for H1, H6 and H7 repeat that list for consignments up to EUR 150, in order: the IOSS user or its indirect representative; the special-arrangements user or its indirect representative; otherwise the importer’s indirect representative; and only after all of those, any other person able to provide the information required. The guidance calls this a cascade: the special-arrangements user acts only where there is no IOSS holder, and the residual letter (d) can apply only after everything else is ruled out.

Letter (d) is how a consumer becomes declarant and debtor. The guidance confines it to the few Member States offering a web-based declaration system to citizens at no extra cost, and only where the IOSS was not used. The guidance adds that customs authorities “may not accept” a declaration carrying an IOSS number where the consumer is the declarant.

Establishment changes the options. A non-EU IOSS holder, special-arrangements user or importer cannot declare in its own name or appoint a direct representative; it needs an indirect representative. EU-established IOSS holders and special-arrangements users can do all three. Double representation is allowed: the IOSS number goes in data element 13 16 034 000, the declarant in 13 05 000 000, and the direct representative of that declarant in 13 06 000 000. Postal operators working under the Universal Postal Union framework may ask the origin post to designate an EU indirect representative to declare all their goods.

Debt follows declaration. Under Article 77(3) of the UCC the declarant is the main debtor, and under indirect representation the person represented is also a debtor. Article 20(5) of the new Code carries the same debtor into the handling fee. Where customs finds a non-compliance debt on goods in a consignment up to EUR 150 that were in a distance sale but not declared as such, Article 79 applies by analogy, and the guidance puts the burden on the operator to prove the import is unconnected to a distance sale.

Annex I, guarantees and the reference amount

Annex I is new to the guidance and aimed at national declaration systems. The EUR 3 duty behaves as a specific duty, so it needs a measurement unit, and there is no Union code meaning “declaration goods item”. The code NAR (number of items) in code list CL349 already exists with a different meaning and cannot be used. The measurement unit field cannot be left empty, so Member States may enter “EUR”, or the national currency code, as the measurement unit. That entry names the unit of calculation, the declaration goods item, and carries no currency meaning.

Two options follow: quantity “1” in data element 14 03 040 006, or amount “1” in 14 03 040 014. Either way, tax type is A00, tax rate (14 03 040 041) is EUR 3 per item, and payable tax amount (14 03 042 000) is EUR 3 per declaration goods item.

For H6 and H7 the guidance gives two calculation routes. Automatic calculation multiplies the number of declaration lines by the relevant amount, and release of the goods counts as notification of the debt. Where that is not possible, customs calculates and notifies later, and may notify at the end of a fixed period of no more than 31 days.

Release requires payment or a guarantee. Articles 89(5) and 95 of the UCC require a comprehensive guarantee to cover release under multiple declarations over a fixed period, which the guidance says is particularly the case for IOSS and special-arrangements users and their indirect representatives. Because Article 20(5) applies customs debt rules to the fee where nothing specific is laid down, guarantee rules apply to the fee by analogy. The transit guarantee does not cover it.

The reference amount under Article 155(3)(c) of the Implementing Regulation must reflect an estimate of the duty and other charges expected, which now includes the fee. Monitoring runs both ways, by the holder under Article 156 and by customs under Article 157, and the guidance suggests audit monitoring after the payment period for aggregated debts, which it puts at a maximum of 10 days. The Commission is in the process of amending Article 158(2) so that AEOs can reduce the guarantee for distance-sale goods to 30% of the relevant part of the reference amount. The guidance pairs that relief with closer AEO monitoring, in particular of record keeping under Article 39(b) of the UCC and financial solvency under Article 39(c).

VAT on the handling fee under IOSS, special arrangements and standard import

The VAT schemes for imported goods in consignments up to EUR 150 are unchanged by the EUR 3 duty, and the guidance refers back to the existing customs guidance on low-value consignments and the VAT e-commerce explanatory notes. Our guide to EU e-commerce VAT, OSS and IOSS covers those filing mechanics.

The new content concerns the fee. The guidance treats it as compensation for a service rendered by customs acting as a public authority, and under Articles 73, 78 first paragraph point (b) and 86(1)(b) of the VAT Directive, as an incidental expense forming part of the VAT taxable amount. VAT is therefore due on the fee, with the route depending on the VAT scheme:

• IOSS: the import is exempt, so no VAT arises on the fee at importation. Where the fee is charged to the consumer at the moment of sale, it forms part of the taxable amount declared in the monthly IOSS VAT return.
• Special arrangements: import VAT is due and is collected from the customer by postal operators or carriers and remitted monthly. The fee forms part of that taxable amount.
• Standard procedure, which covers any value: the fee forms part of the import VAT taxable amount.

Returns run on two tracks. Under the amended Article 148(3) of the UCC Delegated Regulation, a declaration for goods in a distance sale consignment up to EUR 150 can no longer be invalidated because the goods come back after release, so the EUR 3 duty cannot be recovered through that facilitation; the general refund rules in Article 116 of the UCC still apply. The fee itself stays paid. Under the special arrangements and the standard procedure, the VAT charged on the fee is refunded as part of the VAT on the returned importation.

Product identifiers are scheduled to become mandatory on 1 November 2026

Delegated Regulation 2026/1022 applies the product identifier fields from 1 November 2026, with voluntary provision allowed from 1 July 2026. Declarants should confirm the consignment-value scope against the latest adopted Annex B: the guidance says the Commission is amending it to limit the requirement to goods with an intrinsic value not exceeding EUR 150, and that amendment is not yet adopted. The guidance confirms that no sanction or penalty could be imposed during the voluntary period and that effective enforcement starts in November. The stated purpose is risk management: the guidance cites an EU-wide customs control operation under a priority control area (PCA), run by Member State customs authorities with market surveillance authorities, that found a high share of low-value goods imported directly by EU consumers did not comply with EU product rules.

Three identifiers go into data element 12 03 000 000 (Supporting Document), each with its own TARIC document code:

• C127, the merchant product identifier assigned by the online seller, marketplace or platform. Required in every case, and expected to be unique across a platform regardless of how many sellers list the product. For marketplaces, this is one more platform-held dataset alongside the seller data covered in our DAC7 reporting guide for platform operators.
• C128, the non-standardised manufacturer product identifier. Required in every case; where none exists, the manufacturer is expected to assign one, or may reuse its standardised identifier.
• C129, the standardised manufacturer identifier such as an EAN or ISBN, where one exists. Its absence is declared with code Y081 in data element 12 04.

The data element repeats for each product under an item, so two products sharing a classification on one line, each with three identifiers, produce six entries. In a bundle, Y081 is used only if none of the bundled products has a standardised identifier.

The guidance draws a hard line on granularity. Deliberately reporting identifiers at batch or unit level where a model-level identifier exists defeats the purpose of scaling a single control result to all similar products, and the guidance treats that as an infringement, citing Article 274(1)(b) of the new Code on failure to provide complete and accurate data (a provision that applies from 21 September 2027 under Article 287(2) of the Code). Administrative tolerances exist for unprocessed agricultural and perishable goods in Chapters 1 to 15, handmade and artisanal goods (the guidance gives a non-exhaustive list of commodity codes) and antiques, collectibles, art, stamps and coins in headings 9701 to 9706, which may use the conventional values “M-PID” and “NS-PID”. Second-hand, personalised and print-on-demand goods get no tolerance; the identifier of the original or underlying product is reported. Business-to-business flows are in principle outside the requirement.

Points the guidance leaves open

Several items in the October text describe acts or amendments that are not yet in force:

• The fee-setting act was still under scrutiny on 5 October. The legal start of the fee is the tenth day after its entry into force, while the guidance ties Y126 to 1 November 2026. The guidance does not address what happens if those two dates diverge.
• The F00 tax type code, the Article 158(2) guarantee reduction, the Article 201(e) customs warehouse rule and the Annex B narrowing of product identifiers to goods up to EUR 150 are all described as pending or in progress.
• Article 3 of Regulation 2026/382 requires a trade-diversion assessment by 1 October 2026 and every month thereafter. If diversion is found, the Commission is to submit, where appropriate, a proposal extending the EUR 3 duty to all goods in consignments up to EUR 150.
• By 1 December 2027 the Commission must assess whether the EU Customs Data Hub will be able to levy duties on distance sales by 1 July 2028, and may propose extending the transitional duty if it will not. Our EU customs reform and Data Hub timeline sets out the wider phasing.
• The roles described for product identifiers rest on the current Union Customs Code, and a footnote says the guidance will be updated in due time to reflect the new Code.

Frequently Asked Questions

Two orders from the same consumer arrive at the carrier’s hub on the same day. Is that one consignment?

Not where each order travels as its own parcel. The guidance treats goods ordered and shipped separately as separate consignments even if they arrive on the same day as separate parcels, and the same applies to one order dispatched in several parcels. Orders for two different consumers that are meant to reach them separately are always separate consignments in separate declarations. Each consignment is tested against EUR 150 on its own.

Does the EUR 3 duty apply to a EUR 80 parcel bought by a VAT-registered business for its business?

Article 2 of Regulation 2026/382 substitutes the flat duty for IOSS-exempt imports and for goods within the redefined postal consignment, and both are distance sales. The guidance limits distance sales to supplies to non-taxable persons and to taxable persons or non-taxable legal persons whose intra-Community acquisitions are not subject to VAT. A sale to a business whose acquisitions are subject to VAT falls outside that definition, and the guidance does not address its duty treatment, so the applicable tariff treatment is a question for the competent customs authority.

Can a seller established in China declare goods in its own name if it holds an IOSS number?

No. The guidance’s establishment table shows a non-EU IOSS holder can neither declare in its own name nor appoint a direct representative. It must use an indirect representative, who then acts as declarant and debtor, with the IOSS holder also a debtor as the person represented.

Can an express carrier use the H6 dataset for a EUR 600 parcel?

On the text of amended Article 144 of the UCC Delegated Regulation, H6 is lodged by a postal operator for goods conveyed under its responsibility, and the amended Article 1(25) of that Regulation defines a postal operator as one designated by a Member State to provide Universal Postal Convention services. A consignment above EUR 150 that does not qualify for H6 goes in H1, which the guidance makes mandatory above that value.

Do the charges apply to a parcel for a customer in the Canary Islands?

Yes. The Canary Islands are inside the Union customs territory, and the guidance confirms that the EUR 3 duty and the fee apply to goods brought into the parts of the customs territory where the VAT Directive does not apply.

A medical device has no UDI-DI yet. What goes in the standardised identifier field?

Where a UDI-DI exists under the Medical Devices or In Vitro Diagnostic Regulations, it counts as the standardised identifier. Legacy devices not subject to the UDI-DI requirement until 27 November 2026 are treated as compliant if the CELEX number of the applicable act is reported, 32017R0745 or 32017R0746. Other devices report any standardised identifier that exists, and medicinal products under Directive 2011/62/EU may use the product code (AI 01).

Customs decides a bulk import was really a set of grouped distance sales. Does the declaration have to be re-lodged in each consumer’s Member State?

No. The guidance says the Member State where the declaration was lodged is not required to apply Article 221(4) of the Implementing Regulation in that situation and must not refuse the declaration and push the operator to the Member States of consumption. If the declarant declines to request invalidation, customs cannot invalidate on its own and has to calculate the correct debt.

Related Articles

• EU Customs Reform: The Data Hub Timeline for Importers and Traders: the phased timeline of Regulation (EU) 2026/2108 and the move to the EU Customs Data Hub.
• EU E-Commerce VAT at Five: OSS, IOSS and CESOP Obligations: OSS and IOSS filing and the Article 14a deemed-supplier rule for sellers, marketplaces and payment providers.
• DAC7 Reporting for Luxembourg Platform Operators: Who Reports, What Data, and When: seller data reporting obligations for digital platform operators.
• CBAM Definitive Period: The 2027 Declaration Deadline for Importers: another import-side reporting regime, covering declarant authorisation and emissions data.

Key Takeaways

• Recheck line-splitting logic in declaration systems: the guidance applies the EUR 3 duty and the handling fee per declaration line irrespective of quantity, so each extra line in a consignment up to EUR 150 carries both charges, and a line in a larger consignment carries the EUR 2 fee on top of duty at the normal tariff rate.
• Prepare to report TARIC code Y126 in data element 12 04 002 000 on distance-sale declarations at any consignment value. The guidance states this from 1 November 2026, but the fee’s legal start depends on the delegated act’s entry into force, so confirm it against the Official Journal and current TARIC instructions before activating the code in production.
• Map C127, C128 and C129 or Y081 to each product under each item before 1 November, using the model-level identifier where one exists; the guidance treats deliberate batch- or unit-level reporting as an infringement.
• Re-estimate the comprehensive guarantee reference amount to include the fee; AEO holders should watch for the Article 158(2) amendment and its 30% reduction.
• Decide whether the fee is passed to the consumer at checkout: where it is, the guidance puts it in the taxable amount of the IOSS return.
• Customs warehouse operators: where the warehouse prepares goods sold before storage for final distribution, those goods carry the EUR 3 duty where the consignment’s intrinsic value does not exceed EUR 150 and, once it applies, the fee at any value; goods sold while stored await the Article 201(e) amendment.
• Plan for 1 July 2028, when the flat duty ends and normal duty applies to distance sales of any value.

Sources and References

• European Commission, DG TAXUD, “The temporary EUR 3 customs duty and the Union handling fee: Guidance for Member States and Trade”, version of 5 October 2026: guidance PDF
• European Commission, DG TAXUD, “Importation and exportation of low value consignments: The EUR 3 temporary customs duty”, version of 2 June 2026, copy hosted by the Czech Customs Administration: June 2026 guidance PDF
• Council Regulation (EU) 2026/382 of 11 February 2026 amending Regulation (EC) No 1186/2009 as regards the elimination of the threshold-based customs duty relief: EUR-Lex
• Regulation (EU) 2026/2108 of 16 September 2026 establishing the Union Customs Code and the European Union Customs Authority, and repealing Regulation (EU) No 952/2013: EUR-Lex
• Commission Delegated Regulation C(2026) 6694 of 21 September 2026 establishing the amount of the Union handling fee, transmitted with Council document 13480/26: Council register PDF
• Commission Delegated Regulation (EU) 2026/1022 amending Delegated Regulation (EU) 2015/2446 as regards definitions, customs declarations and data elements related to the temporary EUR 3 customs duty: EUR-Lex
• Commission Implementing Regulation (EU) 2026/1200 of 5 June 2026 amending Implementing Regulation (EU) 2015/2447 as regards the temporary EUR 3 customs duty: EUR-Lex
• Council Regulation (EC) No 1186/2009 setting up a Community system of reliefs from customs duty: EUR-Lex
• Regulation (EU) No 952/2013 laying down the Union Customs Code: EUR-Lex
• Commission Delegated Regulation (EU) 2015/2446 and Commission Implementing Regulation (EU) 2015/2447: EUR-Lex (Delegated) and EUR-Lex (Implementing)
• Council Directive 2006/112/EC on the common system of value added tax: EUR-Lex
• European Commission, DG TAXUD news, “Guidance and legal text on temporary flat fee on low-value imports which will apply until 1 July 2028” (8 June 2026): news item

Preparing declarations for the handling fee start

The EUR 3 duty has been live since July, so the remaining build is what the October text adds: line logic that now drives two charges, codes and product identifiers that have to reach the declarant from merchants, platforms and manufacturers, and a guarantee sized for a fee that applies above EUR 150 as well as below it.

The operative check before 1 November 2026 is the Official Journal. The fee applies from the tenth day after C(2026) 6694 enters into force on publication, and that publication date fixes the first declaration on which the EUR 2 per item is due.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.